This program will serve as Part 5 of 6 in the Pass-Throughs and Real Estate Tax Series and Part 6 of 7 in the Tax Audits and Litigation Tax Series. Joining Charles Ruchelman on the panel will be Brendan O’Dell (Office of Tax Policy), Greg Armstrong (IRS Office of Chief Counsel), and Don Susswein (RSM US LLP).

On January 18, 2017, Treasury and the IRS proposed regulations implementing the centralized partnership audit regime enacted in the Bipartisan Budget Act of 2015 (“BBA”). The regulations give the audit regime a broad scope, and provide procedures for electing out, pushing adjustments out to partners, filing requests for administrative adjustments, and determining the ultimate liabilities of partnerships and partners. The government promptly withdrew the regulations due to the new administration’s regulatory freeze, but they will serve as the basis for any future guidance, and the BBA audit regime becomes effective for partnership taxable years beginning on or after January 1, 2018.Our expert panel drawn from Treasury, the IRS Office of Chief Counsel, and the private bar will discuss the policy choices behind the proposed regulations, and what the regulations mean for partnerships, partners, and practitioners.

Pre-registration for this event is encouraged, but walk-ups are also welcomed. As always, please feel free to share this invitation with colleagues. D.C. Bar membership is not required to attend.

This program is available to law students at a discounted rate of $5.00. Please register on-site and provide proof of current law student status.

This catered program is jointly sponsored by the Pass-Throughs and Real Estate Committee and the Tax Audits and Litigation Committee of the D.C. Bar Taxation Section. Doors open at 11:30 am.